FACTA UPDATE: United States, Japan Sign Protocol to Income Tax Treaty

WASHINGTON — In a ceremony held at the U.S. Department of the Treasury today, Treasury Deputy Secretary Neal S. Wolin and Japan’s Ambassador to the United States Kenichiro Sasae signed a new Protocol to the income tax treaty between the United States and Japan. The new Protocol amends the existing tax treaty, concluded in 2003, to bring that agreement into closer conformity with the current tax treaty policies of both the United States and Japan.

“This new protocol reinforces the strong economic relationship between the United States and Japan,” said Deputy Secretary Wolin. “These amendments provide important clarity for investors and businesses and will help foster cross-border investment between our two nations.”

Key aspects of the protocol include:

New rules for the taxation of interest and certain dividends;

Provisions to help resolve certain cases through mandatory binding arbitration; and

Provisions to help the revenue authorities of both nations carry out their duties as tax administrators.

“These amendments will further promote investment between Japan and the United States,” said Ambassador Sasae. “And that investment will add new vitality to both economies and deepen our economic relationship.”

The new Protocol provides for exclusive residence-country taxation of interest and of an expanded category of direct dividends. The new Protocol also amends the provisions of the existing tax treaty governing the taxation of capital gains in a manner that permits the United States to fully apply the Foreign Investment in Real Property Tax Act.

Consistent with a number of recent U.S. tax treaties, the new Protocol provides for resolution through mandatory binding arbitration of certain cases that the revenue authorities of the United States and Japan have been unable to resolve after a reasonable period of time.

In addition, the new Protocol adopts provisions that enable the competent authorities to assist each other in the collection of taxes. The new Protocol also provides for the full exchange of information between the competent authorities to facilitate the administration of each country’s tax laws.

As I tried to point out in the comments on your first post on this, it’s FATCA, not FACTA. “Fatcat” see, which should be a clue about the attitude of the wankers who come up with these rather disturbing moves towards cross border money grabbing.

“In addition, the new Protocol adopts provisions that enable the competent authorities to assist each other in the collection of taxes. The new Protocol also provides for the full exchange of information between the competent authorities to facilitate the administration of each country’s tax laws.”

In other words, if you have income or assets overseas, more and more foreign governments are being bullied into snitching to the IRS. No doubt dimwit lefties think this is a good thing, because the long term consequences of a world where it becomes impossible to hide anything from the government never occur to them.

As I tried to point out in the comments on your first post on this, it’s FATCA, not FACTA. “Fatcat” see, which should be a clue about the attitude of the wankers who come up with these rather disturbing moves towards cross border money grabbing.

“In addition, the new Protocol adopts provisions that enable the competent authorities to assist each other in the collection of taxes. The new Protocol also provides for the full exchange of information between the competent authorities to facilitate the administration of each country’s tax laws.”

In other words, if you have income or assets overseas, more and more foreign governments are being bullied into snitching to the IRS. No doubt dimwit lefties think this is a good thing, because the long term consequences of a world where it becomes impossible to hide anything from the government never occur to them.

Oh shut up.
Most corps and 1%ers use these methods to dodge taxes. They are simply greedy and don’t give a shit about America, only their bottom line.

So, you see a world in which the Rich and the Elite get to have global citizenship, but the rank n’ file don’t is a good thing?

Did I forget to include corporations?

Not sure what you mean by “global citizenship”, and you’re missing my point. If there were no tax havens of any kind, what incentive is there for governments to keep tax rates down ?

Some EU bigwig a few years ago used to go on about “harmful tax competition”, meaning that countries like Ireland with very low corporate tax rates were drawing investment from high tax countries. So, harmful to who ? The only people “harmed” are the big government mandarins who want to expand their own power.

There are other areas where supposedly benign international agreements are in practice a serious encroachment on individual liberty. Britain for example signed a horribly one-sided extradition treaty with the USA a few years ago, which was supposedly only going to be used against the most dangerous terrorists. It has since been used against bankers for example, who had committed no crime under their own country’s laws, but who faced 20 year sentences in the US for breach of some draconian regulation or other.

If you like the idea of the US government being able to grab you or your money anywhere in the world, then either you haven’t thought the thing through, or you’re afflicted with the common lefty assumption that bigger government is always going to be on your side.

Not sure what you mean by “global citizenship”, and you’re missing my point. If there were no tax havens of any kind, what incentive is there for governments to keep tax rates down ?

The incentive that there should be; keeping tax rates at a level they don’t hinder the economy.

Some EU bigwig a few years ago used to go on about “harmful tax competition”, meaning that countries like Ireland with very low corporate tax rates were drawing investment from high tax countries. So, harmful to who ? The only people “harmed” are the big government mandarins who want to expand their own power.

It’s harmful because it becomes a race to the bottom, and turns the marketplace into a zero-sum game. The ideal situation would be roughly equal economic distribution, which would help spur competition and markets and all those other good capitalist things. Whenever capital gets concentrated, in capitalism, it is bad for capitalism. This is a simple concept that most people who think they’re pro-capitalist don’t get, because they’re not really pro-capitalist. Like you. The velocity of money is what is important.

Money that is taxed is not destroyed. It is almost immediately spent by the government, almost all of it in the local economy. Money given to corporations may be spent or may not be, and large amounts of it are funneled into profits for a small amount of people who, likewise, don’t spend it at the same rates as ordinary people do. So the velocity of money is slowed, and the economy suffers.

If you like the idea of the US government being able to grab you or your money anywhere in the world, then either you haven’t thought the thing through, or you’re afflicted with the common lefty assumption that bigger government is always going to be on your side.

The US government should be able to tax all money made by US citizens, because that’s the responsibility of citizenship. Tax-dodging is unpatriotic in the extreme, it’s theft from your fellow citizens.

2) It allows government mandarins to expand their power. (Please spare me)

3) A US UK extradition treaty has allegedly been horribly abused. (And how exactly does this story, if true, justify foreign tax shelters?)

4) US government should be blind to all activities outside the US. (So any person or corporation wealthy enough to park income and assets overseas should pay no US taxes. That might be a hard sell, even to Fox News viewers.)

You talk about corporations as if they were owned by aliens on some distant planet. Most large corporations are owned mostly by institutional investors - pension funds, mutual funds etc, in other words by average people saving for retirement.

“The US government should be able to tax all money made by US citizens, because that’s the responsibility of citizenship. Tax-dodging is unpatriotic in the extreme, it’s theft from your fellow citizens.”

As you ought to know, the US is one of very few countries to tax citizens on their worldwide incomes - Eritrea is another one. No doubt you are proud that your country is in such illustrious company…

Well of course they do. Otherwise you’d get some asshole like Obama once in a while who thinks the optimum tax rate is about 100%. I was thinking of Hong Kong or Singapore rather than Somalia by the way - why do you lefties always go for the straw man thing, as if the only choice was between massive Obama style government or a wilderness

2) It allows government mandarins to expand their power. (Please spare me)

That should be obvious, even to you. Why do you think government departments constantly seek to expand their reach - and their budgets ? Do you think it’s altruism ? (Excuse me for a moment while I fall about laughing - you probably DO think that, don’t you?)

3) A US UK extradition treaty has allegedly been horribly abused. (And how exactly does this story, if true, justify foreign tax shelters?)

Yes, it’s true. And I didn’t mean it as a direct comparison with tax laws. The point is that once you agree to let government have more powers, they will be abused. Pretty much as certain as night following day.

4) US government should be blind to all activities outside the US. (So any person or corporation wealthy enough to park income and assets overseas should pay no US taxes. That might be a hard sell, even to Fox News viewers.)

I refer to my reply to Obdicut above. If you like the idea of the USA being in a very exclusive club along with Eritrea, well, good luck.

You talk about corporations as if they were owned by aliens on some distant planet. Most large corporations are owned mostly by institutional investors - pension funds, mutual funds etc, in other words by average people saving for retirement.

Can you demonstrate this, please, instead of asserting it?

As you ought to know, the US is one of very few countries to tax citizens on their worldwide incomes - Eritrea is another one. No doubt you are proud that your country is in such illustrious company…

This is just a lie, and you can’t read your own wiki link:

In the residential system, residents of the country are taxed on their worldwide (local and foreign) income,

You are one of the worst debaters I’ve ever seen. And you probably think you’re awesome. Honestly, how could someone look at that Wiki article and not understand it? It even has a gigantic table that shows that residents in the UK are taxed on their worldwide income.

So if you haven’t been paying tax on your worldwide income, congrats, you’re a criminal.

You are one of the worst debaters I’ve ever seen. And you probably think you’re awesome. Honestly, how could someone look at that Wiki article and not understand it? It even has a gigantic table that shows that residents in the UK are taxed on their worldwide income.

So if you haven’t been paying tax on your worldwide income, congrats, you’re a criminal.

Go to the bottom of the chart, and look at the countries which tax foreign income of non-resident citizens - the last column on the right. The only countries in that rather dubious club are the USA and Eritrea.

When Alva signed up, before “Don’t Ask, Don’t Tell,” he had to lie on his paperwork. “I knew I was lying,” he says. “But I loved what I did, I loved my job, and I didn’t want to tell anyone. I said, ‘It’s going to be my secret.’ I knew I was not going to be happy in a way, but I knew this was what I wanted.” In 2003 he was deployed to the Middle East, and on March 21 he crossed the border from Kuwait. His unit was part of a huge convoy that stopped outside Basra. Alva got out of his Humvee and went to fetch something from the back of the vehicle. “That’s when I triggered the IED. I was awake, my hearing was sort of gone. My hand was covered in blood and part of my index finger was gone. The chaplain was holding my head and I was telling him I didn’t want to die. I was taken off a helicopter in Kuwait—it was estimated that I was only in Iraq about three hours—and carried into surgery. I woke up later and when I looked down I saw that the right side of my sheet was flat. I cried myself asleep, only to wake up hours later and see that it’s true: My leg is gone.”

As he recuperated, he learned about his inadvertent status. “I don’t know who designated me to be the first. I was never given a certificate or anything. One-millionth shopper. Now I have the dubious distinction of being the first American injured when the war started. It didn’t make it better or worse. I mean, my life was changed forever. I was angry that my leg was gone. Even when I was still in the hospital, hours would go by so slow, and I actually said to myself: ‘Who is going to love me now?’ I’d never really experienced dating anyone. ‘Who is going to love me now? I’m missing a leg.’ “

So, now that women are allowed to serve in combat roles, is the little bigot going to call them “bitches in battledress”? 9_9

So why are you assuming that institutional investors represent money from individuals invested with those institutions?

Go to the bottom of the chart, and look at the countries which tax foreign income of non-resident citizens - the last column on the right. The only countries in that rather dubious club are the USA and Eritrea.

Who gives a shit about non-resident citizens? Your claim was “As you ought to know, the US is one of very few countries to tax citizens on their worldwide incomes”. If you mean to say ‘non-resident citizens’, then sorry you fucked up, but that’s not really my problem is it?

So why are you assuming that institutional investors represent money from individuals invested with those institutions?

Who else’s money would it represent ? Martians ?
Whether those institutional investors are pension funds, banks, hedge funds or whatever, the money ultimately belongs to some individual somewhere, whether it’s someone with a pension or a shareholder in a bank or other corporation. The only exceptions would be college endowments, charitable trusts and suchlike, and I doubt that they account for enough of that 73% to make my point invalid.

Who gives a shit about non-resident citizens?

Apparently the IRS does, not to mention non-resident citizens themselves. That would include Americans working abroad who can no longer open a bank account in a foreign country.

Your claim was “As you ought to know, the US is one of very few countries to tax citizens on their worldwide incomes”. If you mean to say ‘non-resident citizens’, then sorry you fucked up, but that’s not really my problem is it?

Yes, I should have said “non-resident citizens”. I thought it was fairly obvious from the chart what point I was making, but I forgot about your fondness for hair-splitting.

You’re avoiding the main issue, which is that the USA does more to inconvenience its own citizens than almost any other supposedly free country.

It might represent the money of other corporations, for examples, or of very wealthy individuals. Wealth has been increasingly concentrated in a smaller number of hands; pretending this isn’t true isn’t really going to work.

I can see you’re not going to provide anything remotely resembling proof.

Whether those institutional investors are pension funds, banks, hedge funds or whatever, the money ultimately belongs to some individual somewhere, whether it’s someone with a pension or a shareholder in a bank or other corporation. The only exceptions would be college endowments, charitable trusts and suchlike, and I doubt that they account for enough of that 73% to make my point invalid.

Yeah, some individual. It doesn’t mean it’s owned by ‘average’ individuals, which was your claim. You can’t back up that claim.

Yes, I should have said “non-resident citizens”. I thought it was fairly obvious from the chart what point I was making, but I forgot about your fondness for hair-splitting.

And I thought you were just being either stupid or duplicitious, since that’s the usual from you. But why were you trying to make a point about non-resident citizens? Who gives a shit about non-resident citizens (beyond the specialized case of the military and civil service personnel?)

You’re avoiding the main issue, which is that the USA does more to inconvenience its own citizens than almost any other supposedly free country.

Whops, there you go again, claiming this is about citizens and not non-resident citizens.

Man, you have a weird problem with that. It’s almost like your argument is so weak you have to keep trying to assert untruths to make it palatable.

The US and the UK both tax citizens foreign income. In the corner case of non-resident citizens, the US taxes while the UK doesn’t. It has fuck-all to do with the average citizen.

The issue is whether the military should be forced accomodate a small, but rather loud minority, against the overall best interest of the country.

If you allow homosexuals to serve in the military, you’re increasing the pool of potential recruits by about 3%, but probably pissing off about another 20% (at least) of the active military who don’t want to serve alongside them. That’s the figure in the last survey I can remember seeing.

Southerners and blacks for example are much more important demographics for military recruitment, and neither of those groups are exactly famous for their fondness for the fudge-packing community, are they ?

And are these fearless warriors really unable to deal with being referred to as “buggers” ?

And btw, I don’t really have a strong opinion one way or the other about gays - the second person I hired over here was a lesbo (and rather a cute one too…)*. I just don’t see why institutions which have existed for centuries should be forced to change solely for the benefit of a small minority.

*Now you can call me a mysogynist as well as a bigot ! Or you could just get yourself a life instead….

You replied to everything except the point about Americans working abroad, not all of whom are military or civil service. Must be nice to be told that you can’t open a bank account in London now because your government are a bunch of assholes.

It’s not a trivial matter; it shows the underlying attitude of the government towards its citizens.

You replied to everything except the point about Americans working abroad, not all of whom are military or civil service. Must be nice to be told that you can’t open a bank account in London now because your government are a bunch of assholes.

Why do you think you can’t open a bank account in London?

It’s not a trivial matter; it shows the underlying attitude of the government towards its citizens.

Then why doesn’t all the other countries that likewise tax foreign income for their citizens show the same thing?

I left out the word “openly”, and you omitted to explain why it’s a good idea to let them in.

Again, you don’t have to ‘let them in’, they’re already there. What you mean is ‘why isn’t a good idea to honestly acknowledge gay people are in the military and stop pretending they’re not and trying to kick them out’, and that question is kind of obviously answered on the face of it.

The sexuality of the soldier next to you shouldn’t matter. The idea that the recruitment pool will dry up is idiotic and disproved by every other first-world nation. Your blanket condemnation of Southerners and blacks as bigots must be comforting to you, but it’s still fatuous.

Can you cite a drop in military enlistment, post DADT being shot down? According to you, you should be able to. So hop to it.

And I know you like saying tons of stupidly offensive shit because you think it’ll rile people up, but it just makes you look pathetic. It doesn’t even bug me, any more than a guy screaming ‘faggot’ out the window of his trans-am does. It’s just the bray of a jackass.

We already covered that. A lot of financial institutions won’t accept US citizens or even green card holders as clients unless they have about half a million in funds. The reporting requirements are now so onerous that it simply isn’t worth the trouble.

We already covered that. A lot of financial institutions won’t accept US citizens or even green card holders as clients unless they have about half a million in funds. The reporting requirements are now so onerous that it simply isn’t worth the trouble.

Ah, so you were just saying something that wasn’t true again, hyperbolically, because reality doesn’t support your point.

Well, Obdi, EPR-radar and Charles, Thank you for taking care of the trash. I also appreciate the economics lesson.

I’m inclined to continue to misspell the acronym, but that would be snarky, wouldn’t it?

As everyone knows, I’m not the detail-oriented type. It seems to me that regardless of the “reduce taxes here” argument, Those that can have always sequestered their money away in off-shore accounts —no?

Either to escape taxes or to secure a place to live if their own country becomes unsafe. With all the bruhaha over “raising the tax on the rich” it seems we be in better shape if we collect the taxes already owed by the 1%.

Otherwise the middle-class will get squeezed even more. Not for wasteful government spending but for government programs we desperately need.

This is the LGF Pages posting bookmarklet. To use it, drag this button to your browser's bookmark bar, and title it 'LGF Pages' (or whatever you like). Then browse to a site you want to post, select some text on the page to use for a quote, click the bookmarklet, and the Pages posting window will appear with the title, text, and any embedded video or audio files already filled in, ready to go.

Or... you can just click this button to open the Pages posting window right away.

From Sen. Schumer's Facebook page: There are two simple reasons the comparison does not hold water. First, the federal RFRA was written narrowly to protect individuals' religious freedom from government interference unless the government or state had a compelling interest. ...

UPDATE MARCH 30: NEW TIME FOR LIVE STREAM - 11:30 a.m. to 12:30 p.m. PDT NASA's Low-Density Supersonic Decelerator (LDSD) project will be flying a rocket-powered, saucer-shaped test vehicle into near-space from the Navy's Pacific Missile Range Facility on ...

What's this? Another article on Cracked about how incorrigibly tribal-minded us homo sapiens are? Well, yes. But the proverbial devil is in the proverbial details. Proverbially. It's still worth reading. That's what I'm getting at. Everyone is talking about Scientology ...

China attacks the biggest code repository in the world. After battling a distributed denial of service attack for four days, GitHub on Monday was able to restore normal service levels. The primary target of the assault is greatfire.org, which is ...

An American woman--presumably not Muslim, though she doesn't say one way or the other--married to a Libyan man is taken aback when her 9-year-old daughter suddenly wants to start wearing hijab. This is the story of how conflicted she felt ...

NEW YORK, March 27 (Reuters) - Big Wall Street banks are so upset with U.S. Democratic Senator Elizabeth Warren's call for them to be broken up that some have discussed withholding campaign donations to Senate Democrats in symbolic protest, ...

By Lawrence Hurley WASHINGTON, March 30 (Reuters) - The U.S. Supreme Court on Monday declined to hear a new challenge to President Barack Obama's healthcare law that took aim at a bureaucratic board labeled by some Republicans as a ...

Depending on the outcome of a hearing scheduled for Monday, a 33-year-old Indiana woman could face up to 70 years in prison for what she says was a miscarriage. Reproductive rights advocates say her case is a disturbing example ...

The number of things getting plugged into the "Internet of Things" has already reached the point of satire. But there's a new, extremely low power technology that's being prepared for market that could put computing power and network access ...

Are conservatives anti-science? Spoiler: Conservatives aren't anti-science or pro-science. But, they are pro-common-sense. And once more scientists adopt common sense approach to science, they'll find that they have the support of conservative politicians - the people whose job it is ...

cracked.com Once the fighting started, a lot of people died, well over a million on our side alone. For the war to continue, a constant stream of new fighters had to join up, and they didn't have the benefit of ...

Here is an interesting article on one of Tail Gunner Joe's sick witch hunts that has, unfortunately, been forgotten. I try not to feel schadenfreude of the fate of McCarthy's side kick, Ray Cohn, but I never succeed.

About the Graphic How should a woman try to get ahead in a male-dominated workplace? Perhaps the answer lies less on women "manning up" and more in how businesses value their employees. Many women confront this tension as they ...

If we accept the idea of Orthopraxy over Orthodoxy, then what does evangelism look like? What is the Witness of those who try to follow the Way of Christ Jesus? To evangelize is to spread the good news that we ...

A short column in The Nation that is a must read. The primary difference between liberalism and conservatism, at least in theory, is that the latter is an ideology and the former isn't. Conservatism, as Milton Friedman argued, posits that ...

Blow off Snowden all you like, but what was revealed to be true is still true. The NSA lacks oversight with power. FISA is already too much and now they casually exceed even that generous provision. The world first learned ...

This is a powerful admission of culpability and I applaud his courage in making it. It really should be read in its entirety. Glenn Ford should be completely compensated to every extent possible because of the flaws of a system ...

Sarah Vine of the DM gets it wrong: SARAH VINE: Teaching 11-year-olds about rape is a form of child abuse The problem with this country, I've come to realise, is that it treats adults like children and children like adults. ...